20120423Petition to Intervene.pdf

Benjamin J. Otto (ISB No. 8292)
710 N 6th Street
Boise, ID 83701
Ph: [phone] x 12
Fax: [phone]
[e-mail]
Attorney for the Idaho Conservation League
LIJU rbLL
JT(LlT: ,)MMISSIC
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE
APPLICATION OF IDAHO POWER )
COMPANY FOR A DETERMINATION ) CASE NO. IPC-E-12-15
OF 2011 DEMAND SIDE PETITION TO INTERVENE OF THE MANAGEMENT ("DSM")
EXPENDITURES AS PRUDENTLY IDAHO CONSERVATION LEAGUE
INCURRED.
COMES NOW the Idaho Conservation League ("ICL") and hereby requests leave to
intervene in the above captioned matter pursuant to the Idaho Public Utilities Commission Rules
of Procedure, IDAPA 31.01.01.071-073. As discussed below, ICL has direct and substantial
interests in these proceedings, and therefore should be granted intervention.
1. The name of this intervenor is:
Benjamin J. Otto
Idaho Conservation League
710 N. 6th st.
Boise, Idaho 83702
Ph: [phone] x 12
Fax: [phone]
[e-mail]
Please provide copies of all pleadings, production requests, production responses,
Commission orders, and other documents to the name and address above. In the interest of
conserving natural resources and reducing the costs to all parties, please provide hard copies of
pleadings, comments, testimony, or briefs only. Production requests, responses, notices,
Commission orders, and other filings may be submitted via electronic mail in accordance with
IPUC Rules 31.01.01.063.02-03.
ICL'S PETITION TO INTERVENE 1 April 20, 2012
2.Although the Notice of Application indicates this proceeding will use Modified
Procedure, the Commission should grant ICL's petition. The Rules of Procedure state the
Commission "will grant intervention" when a petitioner "shows a direct and substantial interest
in any part of the subject matter of a proceeding and does not unduly broaden the issues[.
IDAPA 31.01.01.074. Idaho Power's Application initiates a formal proceeding. IDAPA
31.01.01.25 and 51 - 52. The rules explain that Modified Procedure is a method for processing a
proceeding. IDAPA 31.01.01.201. ICL submits this petition in order to gain a right to discovery
and a right to participate in any potential hearings or arguments that may occur. IDAPA
31.01.01.038 and 222. Only by gaining status as a party to this proceeding can ICL fully and fairly
represent its direct and substantial interests in this proceeding described in the following
paragraph.
3.Idaho Conservation League claims a direct and substantial interest in this proceeding
arising from the impact to us and on behalf of our members as customers of Idaho Power. ICL
has an interest as a small commercial customer of Idaho Power taking service under schedule 7.
As Idaho's largest state-based conservation organization, we represent over 20,000 supporters,
most of whom are residential customers of Idaho Power. On behalf of our organization and our
members, ICL has a long-standing interest in expanding cost effective energy efficiency and
conservation in Idaho. This proceeding reviews over $42 million spent on DSM activities in 2011
to ensure these investments were cost effective and produced verifiable energy savings. ICL and
our members have a direct and substantial interest in ensuring this ratepayer money was
prudently spent and that Idaho Power continues to pursue all cost effective energy efficiency
opportunities. Because this Commission has directed all utilities to pursue all cost effective
ICL'S PETITION TO INTERVENE 2 April 20, 2012
efficiency and conservation measures, ICL's intervention will not unduly broaden the issues in
this proceeding.
4. ICL intends to fully participate in this matter as a party. The nature and quality of
ICL's intervention in the proceeding is dependant upon the nature and effect of other parties in
this proceeding. If a hearing or argument does occur ICL may introduce evidence, be heard, and
call, examine, and cross-examine witnesses.
WHEREFORE, ICL respectfully requests the Commission grant this petition.
DATED this 20th day of April 2012.
Respectfully submitted,
Benjamin J. Otto
On behalf of the Idaho Conservation League
ICL'S PETITION TO INTERVENE 3 April 20, 2012
CERTIFICATE OF SERVICE
I hereby certify that on this 20th day of April, 2012 I delivered true and correct copies of
the foregoing PETITION TO INTERVENE to the following persons via the method of service
noted:
Hand delivery:
Jean Jewell
Commission Secretary (Original and seven copies provided)
Idaho Public Utilities Commission
427 W. Washington St.
Boise, ID 83702-5983
Electronic Mail:
Julia A. Hilton
Lisa D. Nordstrom
Idaho Power Company
P.O. Box 70
Boise, Idaho 83707
[e-mail]
[e-mail]
Darlene Nemnich
Greg Said
Idaho Power Company
P.O. Box 70
Boise, Idaho 83707
[e-mail]
[e-mail]
Peter J. Richardson
Gregory M. Adams
Richardson & O'Leary, PLLC
515 N. 27th Street
Boise, ID 83702
[e-mail]
[e-mail]
Dr. Don Reading
6070 Hill Road
Boise, Idaho 83703
Telephone: [phone]
Fax: [phone]
[e-mail]
Benjamin J. Otto
ICL'S PETITION TO INTERVENE 4 April 20, 2012